Effective date as last modified: January 21, 2021
FirstCall (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. We recognize information that may be confidential, proprietary or legally privileged and acknowledge that certain information may be protected under HIPAA, or other applicable regulations. FirstCall has policies and procedures that protect the confidentiality of your medical and personal information. These policies prohibit the sharing of any of your personal or medical information with anyone who does not have a right to know. The confidentiality policy, or HIPAA Notice of Privacy Practices, discloses your rights and is sent to all members. If you did not receive a copy and would like one sent to you or, should you have a question, please contact Customer Service at: firstname.lastname@example.org.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.firstcalltelemedicine.com (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy addresses issues set out in the California Consumer Privacy Act of 2018 (“CCPA”), and any terms defined in the CCPA have the same meaning when used in this policy.
This policy applies to information we collect:
This policy does not apply to information collected by:
Children Under the Age of 13
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at email@example.com.
Information We Collect
Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). This personal information is stored and processed in Atlanta, GA, and in other locations for back-up and recovery purposes or to enable us to offer you certain services.
FirstCall’s Website and business operations have collected the following categories of personal information from its consumers within the last twelve (12) months:
A real name (first and last), alias, postal address, unique personal identifier, member identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, number of dependents, driver’s license number, passport number, health or medical history, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, zip code, telephone number, date of birth, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, medical history, medical appointment information, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, or genetic information (including familial genetic information).
D. Commercial information.
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Audio Recordings.
Audio and electronic information recording calls.
I. Sensory data.
Visual, thermal, olfactory, or similar information.
J. Professional or employment-related information.
Current or past job history or performance evaluations.
K. For employees: Professional or employment-related information.
Current or past job history or performance evaluations of FirstCall employees or FirstCall applicants.
L. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
M. For employees: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records for FirstCall employees or FirstCall applicants.
N. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The information we collect on or through our Website also may include:
You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. While the Company has security measures, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Personal information does not include:
FirstCall obtains the categories of personal information listed above from the following categories of sources:
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here https://allaboutdnt.com, for information on how you can opt out of behavioral tracking on this Website and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is statistical data and may include personal information that we may maintain or associate with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for automatic data collection may include:
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
For further information, please visit https://policies.google.com/.
For further information about managing and disabling cookies on your computer, see www.allaboutcookies.org/manage-cookies.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information, below.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. The following mechanisms may provide you with the following control over your information:
How We Use Your Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
FirstCall will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
FirstCall may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
We share your personal information with the following categories of third parties:
Your request for products:
Your request to cancel:
Cancellation of Service – You can cancel your telemedicine service at any time by contacting FirstCall Customer Care at 1-866-920-DOCS. Once canceled, the FirstCall telemedicine service will not renew and you will receive a confirmation email at the email address on file. If you have any additional questions about the cancellation process, please contact the Customer Care Team:
FirstCall Customer Care
Providing you with a quote or processing your application:
We may use your personal information to get in touch with you when necessary to process your application or to provide you with a quote. For example, emails may be sent to you throughout the application process to inform you of the status of your application and to seek additional information that is requested as part of the application. We may also use phone numbers you provide to send you telephone or text messages about your application or account, and such messages may be automatically sent with an autodialer, an artificial or prerecorded voice, or other automation technology.
Customer satisfaction, referrals and other products:
We or our affiliates may contact you to survey your satisfaction with our service, refer our products and services to other people, and/or to inform you of additional products and services. You may opt-out of receiving these additional communications from us by following the opt-out procedures below or as set out in the emails we send to you, as applicable.
California Residents – Your Rights and Choices
The CCPA provides certain consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Disclosures of Personal Information for a Business Purpose:
In the preceding twelve (12) months, FirstCall has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
We disclose your personal information for a business purpose to the following categories of third parties, including within the last 12 months:
Sales of Personal Information:
In the preceding twelve (12) months, FirstCall has sold the following categories of personal information:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
We sell your personal information to the following categories of third parties:
Personal Information Sales Opt-Out and Opt-In Rights:
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
California Consumer Privacy Act Request FirstCall.com/ccpa
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by emailing firstname.lastname@example.org.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
Access to Specific Information and Data Portability Rights:
You have the right to request that FirstCall disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request to email@example.com, we will disclose to you:
Deletion Request Rights:
You have the right to request that FirstCall delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request to firstname.lastname@example.org, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at info@FirstCalltelemed.com.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please email us at info@FirstCalltelemed.com and provide us with legally acceptable evidence of your authorization to act on another’s behalf.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. [However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.]
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format:
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. Specifically, we may transmit your personal information in Excel format.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Accessing and Correcting Your Information
If you are not a California resident, you can review and change your personal information by logging into the Website and visiting your account profile page.
You may also send us an email at email@example.com to request access to or correct any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We maintain reasonable physical, electronic, and procedural safeguards designed to help us protect your non-public personal information against loss, misuse, disclosure and alteration. For example, we use Secure Socket Layer (SSL) technology to encrypt your credit card information when you purchase products through our Website. When you establish an account at FirstCall, a password is generated to help protect your account information. Passwords can be updated. A password is only as strong as you make it. You should select a unique password and keep it safe. You may change your password as often as you wish by going to the Member Log In link of the Website.